Case Digest (G.R. No. 202666) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Rhonda Ave S. Vivares and Sps. Margarita and David Suzara v. St. Theresa’s College, petitioners, the parents of minors Nenita Julia V. Daluz and Julienne Vida Suzara, alleged that in January 2012 their daughters and other students took digital photographs of themselves in undergarments on a beach outing, which were uploaded by classmate Angela Lindsay Tan to Facebook under a “Friends Only” setting. Hearing of these images, computer teacher Mylene Rheza T. Escudero directed her own students to log into their Facebook accounts at the school’s laboratory, viewed and saved the photos—including some depicting alcohol consumption and street attire—then showed them to disciplinary officer Kristine Rose Tigol. St. Theresa’s College, upon investigation, found the minors in breach of its Student Handbook provisions on indecent acts, alcohol use, smoking, and “apparel that exposes the underwear,” and barred them from the March 30, 2012 commencement exercises. Despite a temporary restrai... Case Digest (G.R. No. 202666) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Context
- Petitioners: Rhonda Ave S. Vivares and Spouses Margarita and David Suzara, parents of minor students Julia and Julienne Suzara.
- Respondents: St. Theresa’s College (STC), computer teacher Mylene Rheza T. Escudero, and John Does.
- Circumstances of the Photographs
- January 2012: Minors Julia Daluz and Julienne Suzara and classmates took digital photos in undergarments before changing into swimsuits at a beach party.
- Angela Lindsay Tan uploaded these images to her Facebook profile; privacy setting allegedly “Friends Only.”
- Discovery and School Disciplinary Action
- Escudero learned of photos via students, accessed them on STC computers, and showed them to Discipline-in-Charge Kristine Rose Tigol.
- STC investigation found violations of Student Handbook (alcohol, smoking, indecent acts, improper apparel, online exposure).
- Sanction: barred from commencement exercises scheduled March 30, 2012.
- Parallel Injunction and TRO Proceedings
- March 23, 2012: Dr. Armenia M. Tan filed for injunction to allow Angela to attend graduation; Vivares intervened on March 25.
- March 28, 2012: RTC issued TRO permitting attendance; STC defied TRO citing pending motion for reconsideration.
- Habeas Data Petition
- Petition filed in SP. Proc. No. 19251-CEB arguing unauthorized access and copying of private Facebook data violated minors’ informational privacy.
- RTC issued writ of habeas data (July 5, 2012); respondents filed return denying improper access, disputing reasonable expectation of privacy, and claiming forum-shopping.
- RTC Decision (July 27, 2012) dismissed the petition for lack of proven violation and because photos were publicly viewable.
Issues:
- Primary Issue
- Whether an actual or threatened violation of the minors’ right to informational privacy occurred, justifying issuance of the writ of habeas data.
- Subsidiary Questions
- Whether the writ of habeas data extends beyond extralegal killings and enforced disappearances.
- Whether STC qualifies as an entity “engaged in the gathering, collecting or storing of data.”
- Whether Facebook users have a reasonable expectation of privacy when using privacy settings.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)